Heathrow has announced a series of environmental concessions, based on those proposed by the Airports Commission, which it hopes will persuade the Government to give it permission to build a third runway. Heathrow claims to go beyond the Airports Commission’s recommendations in some cases.

In this article, we look at the key commitments, reflecting what impact they would have on the environmental impacts of a third runway, which the Airports Commission described as ranging from adverse to significantly adverse. We highlighted in our blog following the Airports Commission’s final report that many of the proposed concessions failed to adequately deal with the environmental challenges of a new runway.

Heathrow concession: a partial night flights ban from 11pm – 5:30am with an introduction as soon as the necessary airspace has been modernised after planning consent for the third runway has been secured

Heathrow claims to have exceeded the Airports Commission’s concession by committing to implementing the partial ban as soon as permission is granted, rather than waiting for the third runway to be built, on condition that airspace modernisation takes place. Since airspace ‘modernisation’ is taking place throughout the UK, independent of the expansion question, this undermines the Airports Commission’s claim in its final report that the partial night flights ban is “only possible with expansion”.

However, it is unclear how binding the proposed ban would be. The current restrictions on night flights at Heathrow – and particularly the 5 hour period with no scheduled flights – are a combination of the Government’s night quota and a voluntary agreement with airlines, meaning there are fairly regular breaches of the “ban” between 11:30 and 4:30. Would Heathrow’s commitment be subject to the same infringements?

Heathrow has moved the Commission’s proposed ban back 30 minutes so that early morning flights from East Asia can continue to be scheduled. Based on the scheduled night flights for the most recent winter and summer seasons, the proposed ban could require 13 winter flights to be rescheduled and seven summer flights. This is significant given only 16 flights are currently scheduled between 11:30pm and 6am at Heathrow. However, a recent Mayor of London report identified that a partial ban could in fact lead to a greater number of night flights in the WHO’s eight hour night period (from 11pm to 7am).

The Airports Commission and Mayor of London identified that the economic benefits, in relation to reduced sleep disturbance, of a full night flights ban would far exceed benefits from a partial ban (roughly four times greater).

Given that the Airports Commission and Government have acknowledged the significant health effects of night noise, a binding full night flights ban is needed to protect public health.

Air quality

Airports Commission recommendation: Additional operations at an expanded Heathrow must be contingent on acceptable performance on air quality. New capacity will be released when it is clear that air quality at sites around the airport will not delay compliance with EU limits.

Heathrow: Agree to this recommendation and state that the airport is taking further steps through an ultra-low emissions zone for airport vehicles, developing plans for an emissions charging scheme, and support the Environment Agency scrutinising their plans

AEF has argued that the Airports Commission’s recommendation that expansion should not be allowed to “delay compliance” with the legislation was as a result of an inability to demonstrate that the Heathrow area – which has exceeded air quality limits for many years – could in fact be brought into compliance with legal air quality law if a third runway was built.

Rather than accepting the condition proposed by the Airports Commission, AEF believes permission for a new runway should only be given if it can be proven that this is compatible with bringing air pollution in the Heathrow area within legal limits. The issue of whether other locations in London are forecast to breach legal limits should not be used as an excuse for failing to bring the Heathrow area into compliance with the law.

Airport expansion and climate change

Airports Commission recommendation: None

Heathrow: None

The Airports Commission deflected all responsibility for considering how airport expansion could be compatible with the UK’s climate change legislation to the UK Government. But the Government has still not proposed an effective framework for aviation emissions as recommended by the Committee on Climate Change and Environmental Audit Committee.

The CO2 impacts of expansion remain unaddressed. With UK aviation emissions forecast to be above the maximum level possible under the Climate Change Act even without expansion, and to be higher still with a new runway, the Government should not give a green light to either Heathrow or Gatwick unless it can demonstrate how this would be compatible with UK climate legislation and ambition.